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Care One Mgmt., LLC v. United Healthcare Workers East

3rd Circuit

December 27, 2021

The Third Circuit affirmed the District Court’s grant of summary judgment in this suit, which was “the culmination of a history of conflict and animosity that has unfortunately characterized the relationship between Care One and the Unions.” Care One sued the Unions for damages arising from actions that Care One alleged amounted to a pattern of racketeering in violation of the Racketeer Influenced and Corrupt Organizations Act, based upon its characterization of these actions as “extortionate.” The District Court granted the Unions’ motion for summary judgment and dismissed the complaint. The Court held that no reasonable juror could conclude that the vandalism underlying Care One’s claims could be attributed to union members, much less the Unions themselves. The District Court also concluded that other actions the Unions undertook to exert pressure on Care One—including advertisements, picketing, and attempts to invoke regulatory and legislative processes—were not “extortionate.” The Court further concluded that Defendants lacked the specific intent to deceive and, therefore, were entitled to summary judgment on the mail and wire fraud claims. This appeal followed. The Third Circuit affirmed and held that “the caselaw compels us to conclude that the District Court correctly decided that labor tactics, such as the Unions engaged in here, are not extortionate and accurately reasoned the remaining issues before it.”

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